Placemaker Privacy Policy | Informed Decisions

This policy explains how we handle personal information in connection with Placemaker and the services we provide through it. We handle personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles.

Placemaker is a subscription service for organisations. It is not open to the public. People use it because the organisation they work for holds a subscription and has authorised them to.

2. Who this policy is about

This policy covers three groups of people.

Authorised users – the individuals your organisation authorises to use Placemaker. Most of this policy is about you.
People who contact us – anyone who makes an enquiry, raises a support request or asks to receive our publications.
Anyone whose personal information reaches Placemaker in content uploaded by a subscriber. This should never happen, and section 6 explains why and what we do about it. If you think it has happened to you, section 17 tells you what to do.

3. Collection notices

Where it is appropriate, we give you a collection notice at or before the time we collect personal information from you, or as soon as practicable afterwards.

This policy is a general statement. It does not replace a specific notice we give you in connection with a form, a login, a support request or any other interaction.

4. What personal information we collect

What we collect depends on how you deal with us. It may include:

account and identity information, such as your work email address, name, organisation and role;
information your organisation or its administrators give us to set up, manage or support your access;
support, enquiry and correspondence information, including the content of messages you send us and records of support interactions; and
technical, device and usage information collected through cookies, analytics and similar technologies, such as IP address, browser and device information, session information, pages viewed, features used and interaction events.

We do not want sensitive information. Placemaker is not designed to hold health information, racial or ethnic origin, political opinions, religious beliefs, sexual orientation, criminal record or any other sensitive information within the meaning of the Privacy Act. Please do not give it to us through Placemaker.

5. How we collect personal information

We collect personal information directly from you, from your organisation or its administrators, from your use of Placemaker, and from the service providers who help us operate and support it.

6. Content uploaded by subscribers

Subscribers can upload their own operational data to Placemaker – information about their sites, assets, networks, capacity and utilisation. We call this Client Content.

Client Content must not contain personal information. The subscription agreement prohibits it outright, without exception. Placemaker is not designed to hold information about members of the public, or about the customers, students, residents, patients or clients of the organisations that subscribe to it. It is a planning tool that works with places and premises, not with people.

The subscriber is responsible for checking its content before uploading, and confirms to us on every upload that the file contains no personal information. We also screen uploads ourselves – section 7 explains how.

If personal information does reach Placemaker despite all of that, we treat it as information we were never meant to hold. We remove it as soon as we reasonably can, and we work with the subscriber to understand how it got there and whether anyone needs to be told.

7. Automated screening and artificial intelligence

We screen every file automatically before the upload completes. The screening uses automated tools, including artificial intelligence, to look for content that may contain personal information.

What happens next depends on what the screening finds.

If a file holds records that identify individuals, we block the upload and permanently delete the file. We may do this automatically and without prior notice.
If we flag a particular field as possibly holding personal information, we remove and purge that field by default.
A user may be able to keep a flagged field. If they do, they are confirming to us that the field holds no personal information. Keeping a flagged field is not permission to store personal information in Placemaker, and the prohibition in section 6 continues to apply to it.

We do not keep the original file. Once we have extracted the data we need, the uploaded file is deleted and we do not keep a copy of it. What remains on the platform is the data we derive from it, held in our own format on our Australian infrastructure.

Our screening records do not contain what we found. When screening blocks, deletes or retains something, we record that it happened. We do not copy the personal information or other content that triggered the detection into our logs.

Screening is not a guarantee. It can make mistakes in both directions – it will not catch everything, and it may sometimes flag content that is not personal information at all. It is one safeguard among several, not a substitute for the subscriber checking its own content.

We do not use content uploaded to Placemaker to train or improve artificial intelligence models.

8. Why we collect, hold and use personal information

We collect, hold and use personal information to:

provide, administer and support access to Placemaker and related services;
authenticate users, manage accounts and maintain the security of the platform;
respond to enquiries, investigate issues and provide support;
understand how Placemaker is used and improve it, using aggregated or de-identified information where we can;
send you publications, resources and service-related communications;
where the law permits, send you information about our services, publications or events; and
meet our legal and regulatory obligations.

We do not sell personal information.

9. When we disclose personal information

We may disclose personal information to:

the service providers who help us run Placemaker and our business, including hosting, authentication, analytics, email, CRM, support and IT providers;
the subscribing organisation and its authorised administrators, where this is reasonably necessary to set up, manage, secure or support a user’s access;
our professional advisers, including legal, accounting, audit and insurance advisers; and
courts, regulators, law enforcement agencies and others where the law requires or authorises it.

We only disclose personal information where privacy law permits it and for purposes consistent with this policy or an applicable collection notice.

If you are an authorised user, your organisation’s administrators can see information about your account and your use of Placemaker. That is part of how your organisation manages its own subscription.

10. Where your information is held

The Placemaker platform is hosted in Australia.

Our product analytics service, PostHog, is self-hosted on our own AWS infrastructure in Australia. The system we use to manage support and customer records is also hosted in Australia.

If we ever disclose personal information to a recipient outside Australia, we take reasonable steps to ensure it is protected by contractual, security and governance measures appropriate to the circumstances.

We will tell subscribers before we materially change where the platform, or any component of it, is hosted.

11. Cookies, analytics and telemetry

We use cookies and similar technologies to operate Placemaker, remember your preferences, maintain security, measure performance and understand how the platform is used.

Our analytics and telemetry tools may collect information such as page views, clicks, navigation paths, session activity and device information. Where we can, we use aggregated or de-identified information for product improvement and reporting.

You can usually control cookies through your browser settings. If you disable them, some parts of Placemaker may not work as intended.

12. Automated decision-making

We do not use personal information to make automated decisions that have a legal effect on you, or that significantly affect you in a similar way.

The only automated processing in Placemaker that could touch personal information is the upload screening described in section 7. That screening makes a decision about a file or a field – whether it can be accepted onto the platform – not a decision about a person.

If this changes, we will update this policy before the change takes effect.

13. Direct marketing and service communications

We may send you service, administrative and account-related messages about Placemaker. These include notices about account access, service operation and support. You cannot opt out of these while you remain an authorised user, because they are part of the service.

Where the law permits, we may also send you information about our services, publications, resources or events. You can opt out of these at any time using the unsubscribe link in our messages, or by emailing privacy@id.com.au.

14. Security

We take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure. No system is completely secure, and we do not claim otherwise.

15. How long we keep information

Account, contact and support information: for as long as you are an authorised user, and afterwards for as long as we reasonably need it for support records, legal compliance or to resolve a dispute.
Files uploaded to Placemaker: the original file is deleted once we have extracted the data from it. We keep the data we extract, in our own format, on our Australian infrastructure.
Data derived from uploaded content: for the term of the subscription. After the subscription ends and the agreed export period closes, we delete or de-identify it within 90 days.
Configuration and outputs (such as catchments created, Insight reports and other outputs): for the term of the subscription. After the subscription ends and the agreed export period closes, we delete or de-identify it within 90 days.
Backups, archives and logs: up to 12 months, after which they are deleted or overwritten in the ordinary course of our backup cycle.
Anything we are required to keep by law: for as long as the law requires, or for as long as we reasonably need it to establish, exercise or defend a legal claim.

16. Data breaches

If we experience a data breach that is likely to result in serious harm, we will notify the affected individuals and the Office of the Australian Information Commissioner, as the Notifiable Data Breaches scheme requires.

Where a breach involves content uploaded by a subscriber, we work with that subscriber. Some of our subscribers – particularly government agencies – have their own notification obligations, and we give them the information they need to meet them.

17. Access and correction

You can ask for access to, or correction of, the personal information we hold about you by emailing privacy@id.com.au. We may need to verify your identity before we respond.

If you think your personal information is in content someone uploaded to Placemaker, please tell us at privacy@id.com.au. That content belongs to the subscribing organisation, so we will need to work with them – but tell us, and we will act on it. You do not need to know which organisation uploaded it.

18. Complaints

If you have a concern or a complaint about how we handle your personal information, contact our Privacy Officer using the details in section 20.

We will acknowledge your complaint within 5 business days and respond within 30 days.

If you are not satisfied with our response, you can complain to the Office of the Australian Information Commissioner at www.oaic.gov.au.

19. Changes to this policy

We may update this policy from time to time. We will publish the current version on the ID website, with the date it was last updated, and Placemaker will link to it.

Where a change materially affects a subscriber, we give that subscriber notice in accordance with its subscription agreement before the change takes effect.

20. Contact us

Privacy Officer: ID Consulting Pty Ltd

Email: privacy@id.com.au

Phone: +61 3 9417 2205

Post: Confidential – Privacy Officer, ID Consulting Pty Ltd, L3 96 Flinders Street, Melbourne VIC 3000